Privet Policy

PRIVACY NOTICE

BACKGROUND:

Privet understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

2. What Does This Notice Cover? This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. 3. What is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below. 4. What Are My Rights? Under the GDPR, you have the following rights, which we will always work to uphold: a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11. b) The right to access the personal data we hold about you. Part 10 will tell you how to do this. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more. d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more. e) The right to restrict (i.e. prevent) the processing of your personal data. f) The right to object to us using your personal data for a particular purpose or purposes. g) The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases. h) Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including automated decision-making and profiling. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. How Do You Use My Personal Data? Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes: • Providing and managing your account. • Supplying our products AND/OR services to you. Your personal details are required in order for us to enter into a contract with you. • Personalising and tailoring our products AND/OR services for you. • Communicating with you. This may include responding to emails or calls from you. • Supplying you with information by email AND/OR text that you have opted-in to (you may unsubscribe or opt-out at any time by “opt out” at the bottom other email or by contact us to find out more using the details in Part 11. • Maintaining accurate records of treatments and products bought and used by you.

With your permission AND/OR where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods;

• A minimum of five (5) years, if you have had any treatments AND/OR bought any products with us.

8. How and Where Do You Store or Transfer My Personal Data? Phorest Cloud is hosted in a virtual private network (VPC). This virtual network is dedicated to Phorest and is where all of our servers and databases are hosted in Amazon Web Services. Phorest Cloud uses HTTPS protocol for all transmission of data from our clients to our system, all communication is encrypted. They only store your personal data in the UK. This means that it will be fully protected under the GDPR. If you have filled in a Consultation form in the salon then we will hold your details in a locked filing cabinet. The security of your personal data is essential to us, and to protect your data, we take a number of in salon important measures, including the following: • All your digital data is stored off site by a third party • Only staff with a code can access it. Once those people no longer require access we change their passcodes • All hard copies are stored on site and are locked in a filing cabinet. • The cabinet is locked in the evening and the keys are stored safely

9. Do You Share My Personal Data? We will not share any of your personal data with any third parties for any purposes, subject to one important exception. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data? If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within less than ONE month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You? To contact us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of The Manager Email address: bookings@privetbody.com . Telephone number: 02072215674. Postal Address: Privet 214 Kensington Park Road, Kensington, London, W11 1NR

12. Changes to this Privacy Notice We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.